Quinn v. Commissioner of Internal Revenue

HOLMES, Circuit Judge.

This petition involves the right of petitioners to deduct, in their 1936 income-tax return, (1) a debt alleged to have been ascertained to be worthless, and charged off during the taxable year, and (2) a payment claimed to have been made for professional services, deductible as an ordinary and necessary business expense.

On the first question, the undisputed facts show that the taxpayer was engaged in buying and selling securities, and that he owned the controlling interest in the Sal-Mar Oil Corporation and in other companies. He kept no account books, and filed his…